Q: What is CARF and why does it matter from 2026?

CARF (the OECD’s Crypto-Asset Reporting Framework) is a new international standard for the automatic exchange of information on crypto-asset transactions, which Switzerland is adopting, with effect building from 2026. It will require crypto-asset service providers to collect and report information on their users and transactions to the tax authorities for exchange with partner jurisdictions, much as the existing standard does for financial accounts. For a token issuer or crypto-asset business, CARF means new due-diligence and reporting obligations that have to be built into operations, not bolted on later. We factor CARF readiness into the regulatory set-up, so a token or stablecoin business is prepared for the reporting regime as it comes into force.

Question 1

Why do I need a FINMA token classification?

Accepted Answer

Because how a token is classified determines which Swiss financial laws apply to it, and getting that wrong can mean issuing an unauthorised security, taking unauthorised deposits, or running an unauthorised collective investment. Before issuing or operating a token, you need to know whether it is a payment token, a utility token, an asset token or a hybrid, and what each classification triggers. A written assessment, and where appropriate a ruling from FINMA confirming its view, turns that uncertainty into a defensible position you can build and raise money on. A token launched without resolving its classification is a regulatory risk that can surface at exactly the wrong moment. We obtain the classification and, where useful, the FINMA ruling.

Question 2

What are FINMA's token categories?

Accepted Answer

FINMA works with three principal economic categories, plus hybrids. Payment tokens are intended as a means of payment and have no further function; utility tokens give access to a digital application or service; and asset tokens represent an asset such as a debt or equity claim, a participation, or an entitlement to a stream of value; these are generally treated as securities. A token can also be hybrid, combining functions, and is then assessed against each. The classification is economic and substance-based, not a matter of what the token is called. We analyse the token&rsquo;s real function and rights to place it in the right category, because that placement drives everything that follows.

Question 3

How are stablecoins treated in Switzerland?

Accepted Answer

It depends on what the stablecoin is backed by and how the backing is held; there is no single stablecoin rule. A stablecoin referencing a single fiat currency, with redemption claims against the issuer, can fall within the deposit concept and so the banking or FinTech regime; one backed by a basket or by commodities can raise collective-investment questions; one representing other assets can be a security. FINMA assesses each on its structure, looking at the reference asset, the redemption right and how reserves are held and protected, and AML duties apply throughout. Because the treatment turns on structure, the regulatory position should be settled before launch. We assess the stablecoin across the regimes and obtain FINMA&rsquo;s position where it matters.

Question 4

When does a token become a deposit or a security?

Accepted Answer

A token edges into the deposit concept when the holder has a repayment claim against the issuer for funds received (common in fiat-referenced stablecoins and certain payment models), bringing the banking or FinTech regime into play. A token is generally a security, more precisely an asset token, when it represents a financial claim or participation: a debt, an equity-like interest, or an entitlement to profits or value. Each characterisation carries heavy consequences: deposit-taking needs a licence, securities issuance triggers prospectus and other rules. The boundaries are technical and the same token can sit near more than one line. We resolve which lines a token crosses, in writing, before it is issued.

Question 5

What is a FINMA ruling and when is it worth obtaining?

Accepted Answer

A FINMA ruling, in this context, is a written confirmation of how FINMA views a specific token or model: for example, that a given token is a payment token and not a security, or that a stablecoin structure does or does not constitute deposit-taking. It is worth obtaining where the classification is material to the business and not obvious, where investors or partners need certainty, or where the consequences of being wrong are serious. It turns a reasoned legal view into a position confirmed by the regulator. Not every token needs a ruling (a clear case can rest on a well-documented assessment), but for novel or borderline structures it is valuable. We advise whether a ruling is warranted and prepare the submission.

Question 6

What is CARF and why does it matter from 2026?

Accepted Answer

CARF (the OECD&rsquo;s Crypto-Asset Reporting Framework) is a new international standard for the automatic exchange of information on crypto-asset transactions, which Switzerland is adopting, with effect building from 2026. It will require crypto-asset service providers to collect and report information on their users and transactions to the tax authorities for exchange with partner jurisdictions, much as the existing standard does for financial accounts. For a token issuer or crypto-asset business, CARF means new due-diligence and reporting obligations that have to be built into operations, not bolted on later. We factor CARF readiness into the regulatory set-up, so a token or stablecoin business is prepared for the reporting regime as it comes into force.

Question 7

How does this connect to the 2027 stablecoin framework?

Accepted Answer

The proposed 2027 reform would create a dedicated route for certain stablecoins, allowing the new Payment Instrument Institutions to issue fully-backed, single-currency “stable payment crypto-assets” under defined conditions: segregation, redemption at par, robust governance. That gives some stablecoin models a clearer home than today’s patchwork of deposit, collective-investment and securities analysis. For a stablecoin business planning now, the question is whether to build on the current regime or position for the new one. The classification and ruling work feeds directly into that decision. We assess the token today and advise how it fits the incoming framework, coordinating with our payment-licence work.

Question 8

Do AML rules apply to token issuers?

Accepted Answer

Yes, in most cases. Issuing payment tokens, operating stablecoins and many other crypto-asset activities make the operator a financial intermediary with anti-money-laundering duties under the Anti-Money Laundering Act, requiring the full AML framework and, typically, SRO affiliation or supervision. The AML dimension is independent of the token-classification question: a token can be a non-security payment token and still carry heavy AML obligations because it moves value. Token projects sometimes resolve the securities question and overlook AML entirely, which is a serious gap. We address the AML position alongside the classification, and can build and run the AML framework that a token business needs.

Question 9

How does the financial-regulation view differ from the crypto desk's?

Accepted Answer

They are two sides of the same project. The financial-regulation work here is the regulatory positioning: classifying the token, obtaining the FINMA ruling, resolving the deposit, securities and collective-investment questions, and CARF readiness. The crypto desk handles the execution: structuring the issuance, the custody and trading arrangements, the DLT and technical dimension. A serious token or stablecoin launch needs both: the regulatory position settled and the project built to match it. We run the classification and ruling side and coordinate closely with the crypto desk so the legal position and the build are consistent, rather than a regulatory opinion that the implementation then departs from.

Question 10

What happens if I launch a token without resolving its classification?

Accepted Answer

You carry an unquantified regulatory risk that can crystallise badly. A token that turns out to be an unauthorised security, an unauthorised deposit-taking instrument, or an unauthorised collective investment exposes the issuer to FINMA enforcement, the unwinding of the offering, liability to holders, and reputational damage, often surfacing just when the project is raising money or scaling, which is the worst moment. Investors and serious partners increasingly ask for the regulatory position before committing, so the absence of one is itself a commercial obstacle. The classification is cheap relative to the risk of getting it wrong. We resolve it before launch, so the token is built on a confirmed footing rather than a hope.

Question 11

Can Goldblum obtain token and stablecoin rulings?

Accepted Answer

Yes. We analyse the token&rsquo;s real economic function and rights, classify it across the payment, utility and asset categories, resolve the deposit, securities and collective-investment questions, and, where it is warranted, prepare and obtain a FINMA ruling confirming the position. We address the AML obligations alongside, build CARF reporting readiness into the set-up, and advise how a stablecoin fits the incoming 2027 framework. Throughout, we coordinate with our crypto desk so the regulatory position and the technical build match. The aim is a token or stablecoin launched on a confirmed regulatory footing (defensible to FINMA, to investors and to partners) rather than an unresolved risk.

FINMA stablecoin &
token rulings

The token’s regulatory position, confirmed.

Why classification decides everything

Who this is for

Where it fits

Token categories: what each triggers

Placing the token by economic substance

From analysis to FINMA ruling

Token analysis

Regime mapping

Ruling submission

AML & CARF readiness

Build & coordinate

What it costs

What a sound classification requires

Resolving the securities question is not the whole job

Position and build, together

Recognised by IFLR1000

Beyond the securities question

Position matches the build

Next in this practice

Payment & e-money licence

Banking & FinTech licence

Crypto & DLT desk